(8) INCOME TAXES

The Company’s provision/(benefit) for income taxes from operations are summarized as follows:


	June 30,
	2017		2016		2015
	(in millions)
Current Income Taxes
Federal	$	1.6	$	(1.3)	$	1.7
State		6.3		8.7		4.4
Foreign		(2.1)		3.9		(1.6)
Total	$	5.8	$	11.3	$	4.5
Deferred Income Taxes
Federal	$	13.3	$	7.3	$	(8.7)
State		2.4		(2.3)		(6.9)
Foreign		(3.1)		(7.8)		2.3
Total		12.6		(2.8)		(13.3)
Total provision/(benefit) for income taxes	$	18.4	$	8.5	$	(8.8)

The United States and foreign components of income/(loss) from operations before income taxes are as follows:


	June 30,
	2017		2016		2015
	(in millions)
United States	$	66.6	$	(46.9)	$	(159.7)
Foreign		37.5		(20.8)		(4.4)
Total	$	104.1	$	(67.7)	$	(164.1)

The Company’s effective income tax rate differs from what would be expected if the federal statutory rate were applied to earnings before income taxes primarily because of certain expenses that represent permanent differences between book and tax expenses and deductions, such as stock-based compensation expense.

We file income tax returns in various federal, state, and local jurisdictions including, but not limited to, the United States, Canada, United Kingdom and France. In the normal course of business, we are subject to examination by taxing authorities throughout the world. With few exceptions, we are no longer subject to income tax examinations by tax authorities in major tax jurisdictions for years before 2012.

A reconciliation of the actual income tax provision and the tax computed by applying the U.S. federal rate to the earnings before income taxes during the years ended June 30, 2017, 2016 and 2015 are as follows:


	June 30,
	2017		2016		2015
	(in millions)
Expected provision/(benefit) at the statutory rate	$	36.4	$	(23.8)	$	(57.4)
Increase/(decrease) due to:
Stock-based compensation		(11.7)		27.9		59.4
State income taxes, net of federal benefit		2.9		(2.1)		(7.4)
Transaction costs not deductible for tax purposes		1.9		1.5		0.7
Change in statutory tax rate		(1.4)		(3.6)		(2.2)
Change in valuation allowance		(10.2)		2.8		—
Foreign tax rate differential		(3.9)		2.7		0.6
Other, net		4.4		3.1		(2.5)
Provision/(benefit) for income taxes	$	18.4	$	8.5	$	(8.8)

As of June 30, 2017, the Company recorded a $0.2 million liability for uncertain tax positions and accrued interest related to state taxing jurisdictions. We recognize interest and penalties related to uncertain tax positions in income tax expense. Currently, the company is under audit by several US states for fiscal years 2013 to 2016.

Deferred income taxes reflect the tax effects of temporary differences between the carrying amounts of assets and liabilities for financial reporting purposes and the amounts used for income tax purposes. The tax effect of temporary differences that give rise to significant portions of the deferred tax assets and deferred tax liabilities are as follows:


	June 30,
	2017		2016
	(in millions)
Deferred income tax assets
Net operating loss carry forwards	$	715.2	$	563.9
Tax credit carry forwards		22.6		17.2
Deferred revenue		405.9		318.3
Accrued expenses		40.0		40.2
Other liabilities		17.4		25.5
Reserves against accounts receivable		18.2		14.8
Deferred compensation		20.3		15.5
Total deferred income tax assets		1,239.6		995.4
Valuation allowance		(111.1)		(135.3)
Net deferred tax assets		1,128.5		860.1
Deferred income tax liabilities
Property and equipment		712.2		559.2
Intangible assets		412.4		321.5
Debt issuance costs		5.8		13.7
Total deferred income tax liabilities		1,130.4		894.4
Net deferred income tax liabilities	$	(1.9)	$	(34.3)

As of June 30, 2017, the Company had $1,662.5 million of U.S. federal net operating loss ("NOL") carry forwards. The Company utilized approximately $88.6 million of U.S. federal NOL carry forwards during Fiscal 2017. The Company has completed several acquisitions in which it acquired net operating loss tax attributes as part of the purchase. These acquisitions, however, were considered a "change in ownership” within the meaning of Section 382 of the Internal Revenue Code and, as a result, such NOL carry forwards are subject to an annual limitation, reducing the amount available to offset income tax liabilities absent the limitation. Currently available U.S. NOL carry forwards as of June 30, 2017 are approximately $952.0 million. An additional $167.0 million will become available for use during fiscal year ended June 30, 2018. The Company's NOL carry forwards, if not utilized to reduce taxable income in future periods, will expire in various amounts beginning in 2019 and ending in 2036.

As of June 30, 2017, the Company had approximately $389.5 million of foreign jurisdiction net operating loss carry forwards, primarily in Canada, the United Kingdom and France. The majority of these foreign NOLs have a valuation allowance reducing the value of the corresponding deferred tax asset in the financial statements due to recent losses. It is reasonably possible that the Company may reverse the valuation allowance recorded on certain foreign subsidiaries’ deferred tax assets in the near future.

As of June 30, 2017, the Company had tax-effected state net operating loss carry forwards of approximately $42.1 million, which are subject to limitations on their utilization and have various expiration dates 2017 through 2036. The Company believes that only $39.3 million of this balance will be utilized.

Management believes it is more likely than not that it will utilize its net deferred tax assets to reduce or eliminate tax payments in future periods, with the exception of deferred tax assets related to certain foreign subsidiaries. The Company’s evaluation encompassed (i) a review of its recent history of taxable income for the past three years and (ii) a review of internal financial forecasts demonstrating its expected ability to fully utilize its deferred tax assets prior to expiration.

At June 30, 2017, the positive undistributed earnings of the Company's foreign subsidiaries amounted to $61.8 million. Those earnings are considered to be indefinitely reinvested and, accordingly, no income taxes have been provided thereon. The amount of income taxes that would have resulted had such earnings been repatriated is estimated to be $21.3 million.